The defendant accidentally drove onto a police officer foot and then refused to move the car when asked. The court held that the actus reus of battery could be a continuing act, so that the defendant failure to remove the car coincided with the necessary mens rea, and upheld the conviction for assaulting a police officer in the execution of his duty.

The appellant was convicted under the Dangerous Drugs Act 1965 for allowing her farmhouse to be used for smoking cannabis. The House of Lords quashed the conviction, holding that the offence required proof that she knew the premises were being used for that purpose. The decision reinforced the presumption that mens rea is an essential element of criminal offences carrying imprisonment unless Parliament clearly excludes it.

The House of Lords determined the mental element for malicious wounding under section 20 and assault occasioning actual bodily harm under section 47 of the Offences Against the Person Act 1861. For section 20, the prosecution must prove intention or subjective recklessness as to causing some physical harm, not necessarily serious harm. For section 47, the mens rea is intention or subjective recklessness as to committing an assault or battery, with no requirement of foresight of actual bodily harm.